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Introducing the “In Favour Of” filter in Case Laws.
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of <h1>Business Profits Taxation: Home State Primacy with Permanent Establishment Exceptions Under Specific Functional and Risk Criteria</h1> The statutory provisions detail taxation rules for business profits between contracting states. Profits are primarily taxable in the enterprise's home state, but can be taxed in the other state if a permanent establishment exists. Profits are attributed based on the permanent establishment's hypothetical performance as an independent entity, considering functions, assets, and risks. The provisions aim to prevent double taxation through mutual agreement and ensure fair taxation of business income across jurisdictions.
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